Regulation 11
FANIL adjusted to be before tax
of Multinational Enterprise (Minimum Tax) Regulations 2024
The FANIL of a constituent entity of an MNE group for a financial year must be adjusted by adding back any positive amounts and excluding any negative amounts of tax expense (including a deferred tax expense) in respect of the following, as reflected in the FANIL:
a covered tax (whether or not the income to which the tax relates is excluded from its GloBE income or loss);
any MTT, or any qualified IIR;
any DTT, or any qualified domestic minimum top‑up tax;
a qualified UTPR;
any disqualified refundable imputation tax (as defined in paragraph 1(7) of the First Schedule to the Act);
any tax payable by a life insurer in respect of amounts accruing to or paid to policyholders.